2 After concessions by the parties, the issues for decision are: (1) Whether petitioner had gross receipts during the taxable year 1988 from a business known as Ticketline. We hold that he did. (2) Whether petitioner has substantiated cost of goods sold for Ticketline for the taxable year 1988. We hold that petitioner has substantiated cost of goods sold in the amount of $143,004. (3) Whether petitioner is liable for self-employment tax for the taxable year 1988 from his activities with Ticketline. We hold that he is. (4) Whether the costs associated with petitioner's nutritional information system are deductible pursuant to section 174. We hold that they are not. (5) Whether petitioner is liable for the addition to tax pursuant to section 6651(a)(1) for failure to file timely Federal income tax returns for the taxable years 1988 and 1989. We hold that he is. (6) Whether petitioner is liable for the addition to tax pursuant to section 6653(a)(1) for negligence for the taxable year 1988. We hold that he is. (7) Whether petitioner is liable for the addition to tax pursuant to section 6661 for a substantial understatement of tax for the taxable year 1988. We hold that he is.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011